Select Committee on European Union Written Evidence

Memorandum by the Royal National Institute for the Blind (RNIB)


  The Royal National Institute for the Blind is the largest organisation in the United Kingdom working with and on behalf of blind and partially sighted people. We work to influence the development of public policy at local, national and European levels in the interests of visually impaired people. RNIB is a leading member of the European Blind Union, which is the only pan-European organisation representing the interests of blind and partially sighted people, who number 1.7 million people in the United Kingdom and 7.4 million people in the EU. As the profile of the visually impaired population is biased towards the older age groups, the increase in the number of elderly people across the EU will be accompanied by an increase in the number of visually impaired people.


  RNIB believes that it is important for the EU institutions and national governments/agencies to use the opportunity presented by the coming e-commerce directive and the e-Europe initiative to take steps to enable the United Kingdom's and EU's visually impaired citizens to enjoy equal access to e-commerce. If these opportunities are not used imaginatively to this end, many people will face exclusion from this growing sector's services, as well as providers of many online e-commerce services needlessly excluding themselves from millions of potential customers.


    (a)  On question 2 posed by the Sub-Committee—RNIB believes that the European Commission's eEurope Action Plan does offer some realistic means of promoting e-commerce. We welcome the early results of the eEurope consultation process, in which RNIB took part, as posted on the Commission's "Feedback to the eEurope mailbox page". In particular the Commission draws attention to the suggestion that the Web Accessibility Initiative (WAI) guidelines should be widely adopted, with the Commission undertaking to actively consider this and encourage the Member States to do likewise. We urge the Sub-Committee to add its support to this suggestion in its reports to and contacts with the United Kingdom's Government/EU institutions. Clearly an active promotion of the WAI guidelines by the EU and Member States to the e-commerce sector would assist e-commerce providers to meet the ambitions of the e-commerce directive on subjects such as the duty to provide information about themselves, as well as helping providers ensure that avoidable design errors did not exclude them from millions of potential customers.

    (b)  One potentially useful way to encourage best practice amongst electronic commerce providers as regards accessibility of their services to visually impaired and other disabled people, would be for the Member States and Commission to consider means of public recognition/financial incentives for service providers who meet the standards of codes of conduct/standards agreements.

    (c)  The same Commission mailbox page also records the support of industrial respondents for "sunset clauses" to allow for regular updating of e-commerce regulations. RNIB believes that such clauses should allow for updating of any codes of conduct/standards agreements which we urge the EU institutions, member states, e-commerce providers and consumer organisations to agree. Crucially, disabled people's organisations such as the European Blind Union and European Disability Forum need to be involved in any such codes/standards preparation. As access technologies and design for all/accessibility guidelines are updated these should be fed into the updates of any codes of conduct/standards agreements the EU arranges.

    (d)  On question 3 posed by the Sub-Committee—whilst strongly supporting the agreement and adoption of codes of conduct, RNIB would urge the EU institutions and Member States to be always prepared to propose stronger intervention through legal or regulatory means as far as practicable, where cases of inaccessible practices by e-commerce providers are brought to the attention of the EU/member state authorities and the providers prove unwilling to take simple steps to make their services accessible to visually impaired or other users.

28 February 2000

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